Hazardous Waste Management System: Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for Solvent-Contaminated Wipes

The American Petroleum Institute (API) generally support’s EPA’s proposed rule and applauds the Agency’s efforts 1) to promote national consistency in regulations governing industrial wipes, 2) to reduce generators compliance costs and provide greater regulatory flexibility in the management of industrial wipes, and 3) to facilitate pollution prevention and waste minimization opportunities. These comments provide API’s position on some of the key provisions in the proposed rule and also request clarification on regulatory interpretations that are included in the preamble to the rule, some of which appear to modify existing regulatory positions and interpretations. In particular, API believes that EPA should not in the context of this rulemaking make changes to generally applicable regulations and policy interpretations under RCRA. API’s specific comments are discussed in the attached document.